Summary of FEE Study Transnational Organisations and Practices within the Accountancy Profession Martin Manuzi Director, European Office and Head of European Affairs, Objectives of the study Promote wider understanding of the accountancy profession s response to the internationalisation of business needs - Explain the drivers : regulatory and legal context - Describe organisational models of main trans-national service providers Illustrate diversity / similarities in relation to structure, governance and operational arrangements of service providers Summarise views on impact of regulatory requirements, notably the network definition Provide stimulus for considering regulatory framework from European internal market and broader trans-national perspectives 1
Key findings and conclusions (1) The accountancy profession s trans-national evolution within Europe has been strongly moulded by a fragmented, jurisdiction-specific approach to regulation, and different legal systems and cultures - Rules on: ownership, qualification, registration, market access, service provision Unevenness of liability regimes and declining insurance: growing influence over time To date modest trans-national coordination of regulatory policy to allow for more integrated structures. The impact of relevant EU legislation is still to be seen at Member State level Key findings and conclusions (2) Three distinct structural models of trans-national organisation and practice: i) an international association of independent firms coordinated by a separate legal entity ii) an integrated international partnership (IIP) iii) a national practice with subsidiaries in other jurisdictions International association model is most predominantly used by profession Other two models are of importance at current time and may grow in importance Interaction between models is evolving, especially between association and integrated international partnership models 2
Key findings and conclusions (3) International associations: Structural arrangements: very high degree of commonality Key element: legally independent member firms servicing clients Governance / structures and operational arrangements: major differences Three discernible categories: tool to assist interpretation of findings (next slide) Variable degree of control arising from economic dependency of member firm Key Findings and Conclusions (4) High Frequency and extent of transnational operations / referrals A first level of transnational interaction and coordination A considerable to high degree of trans-national interaction and coordination and to some degree integrated trans- national functioning An increased and evolving level of trans-national interaction but in some respects a still modest degree of trans-national coordination Low Size of central budget and shared resources Low High Interaction, coordination and integration between association member firms 3
Key Findings and Conclusions (5) Key findings and conclusions (6) Integrated International Partnership (IIP): One grouping as a whole describes itself as such but model employed more extensively Key elements of the model are evolving within certain associations Model has many elements of cross-border sharing deriving from common ownership but no sharing of legal liability Management and control appear more direct, particularly in comparison with A and B associations 4
Key findings and conclusions (7) National practice with subsidiaries: Least commonly used and most geographically limited Highest degree of management and control of all models Appears to be important model for providing non-statutory audit services Future evolution in light of revised Statutory Audit Directive and other EU Directives in Internal Market for services sphere? Network definition Overall high degree of awareness that network is now a legal definition C associations / IIP: recognition that network definition is applicable, but concerns over compliance costs due to independence gold plating B associations: i) concerns over costs / benefit ii) public interest relevance? iii) unevenness of implementation iv) liability But also some view benefits in terms of market perception A associations do not consider their organisations to be networks in some cases operational coordination has been reduced to ensure that this is the case. network removed from self-descriptions - alliance, affiliation and association. 5
FEE Policy conclusions EC Auditor Liability recommendation is to be welcomed Member States should implement Statutory Audit Directive with transnational organisations in mind Consistency in interpretation of network definition is critical: IFAC guidance Clarification of pending questions regarding Internal Market Directives could be highly relevant (FEE study November 2007): cross border provision of services, infrastructure Study Dissemination / follow-up Publication April 2008 Presentation to European Group of Auditor Oversight Bodies (EGAOB) Joint FEE/ Roundtable in London with European Commission / UK Financial Reporting Council Audit Firms Working Group Developments within major players towards trans-national partnerships 6
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